Does a settlement agreement need to be held to a higher standard of fairness than a class representative?

Where settlement occurs prior to class certification, courts must hold the settlement agreement to a "higher standard of fairness." Hanlon v. Chrysler Corp., 150 F.3d 1011, 1026 (9th Cir. 1998) ("The dangers of collusion between class counsel and the defendant, as well as the need for additional protections when the settlement is not negotiated by a court designated class representative, weigh in favor of a more probing inquiry"). Because a settlement agreement

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